As you should be aware by now, Illinois State law was passed in late 2008 that requires any group “installed, modified, or renewed” after 6/1/09 is required to allow dependents to stay on the plan until age 26 regardless of student status (or to age 30 if a Military Veteran Dependent).
It is important to note that once a group renews OR DOES A PLAN CHANGE mid year, there is a one-time 90 day period during which dependents under the age of 26 that had been removed previously from the plan (for not meeting the definition of a full time student) are able to re-enroll on their parent’s plan as a dependent. In the event that an employee misses this legislated window, they will have to wait until the next annual open enrollment to add the dependents. We have noticed some groups implementing a plan change (after 6/1) without realizing that the one-time 90 day window has started as a result of the plan change.
Age 26 Individual Products (Consumer Markets) Administration
Remember the entire BCBSIL INDIVIDUAL business renews on January 1 of every year. NOTE the BLOCK RENEWAL is a completely separate transaction from the individual's “rating anniversary”. On the Consumer Markets side (individual products), regardless of the date of the policyholder's annual rate adjustment, the actual contract renews with the block on a January 1 cycle. Therefore, Consumer Markets clients will be able to add dependent children to the policy for 90 days after 1/1/2010. If this initial 90 day window is missed, the children will be subject to medical underwriting to come onto the parent's plan.
Note, beginning November 2008, BCBSIL discontinued removing dependents from coverage who would have otherwise “aged out” (due to reaching limiting age and not meeting student status).
GROUP: IL Continuation Reminder
In June, the governor signed a law increasing the Illinois Continuation eligibility time frame to 12 months (up from 9 months). Once again, this is phased in by groups being “issued, delivered, amended or renewed”. Any group with people on Illinois Continuation that switch carriers, make a plan change, or renew will need to modify/extend any current and future Illinois Continuation eligibility to 12 months.
The state has also temporarily modified the minimum time served provision in order to be eligible to elect for Illinois Continuation. Prior to the passage of the above referenced law, a member had to be on the plan for 90 days in order to be eligible for Illinois Continuation. The state has revised that to read those employees that were involuntarily terminated between September, 2008 and December 31, 2009, and were on the plan for a single day are eligible to continue on Illinois Continuation.
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